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CPSC Invites Public Comment on Revised ASTM Standard for Portable Hook-On Chairs

  • By: Learn Laws®
  • Published: 01/29/2026
  • Updated: 01/29/2026

The U.S. Consumer Product Safety Commission (CPSC) has issued a notice in the Federal Register seeking public comments on a revised voluntary standard for portable hook-on chairs. Published on January 29, 2026, this notice addresses ASTM F1235-25, the latest update to the Standard Consumer Safety Specification for Portable Hook-On Chairs. The CPSC is evaluating whether this revision improves safety compared to the current mandatory standard, ASTM F1235-18, which is incorporated into federal regulations at 16 CFR part 1233. Comments are due by February 12, 2026, and will inform the Commission's decision on adopting the new standard. This development underscores ongoing efforts to enhance child safety in durable infant products, as mandated by the Consumer Product Safety Improvement Act of 2008 (CPSIA). Portable hook-on chairs, designed to attach to tables for infant seating, have been subject to federal oversight since 2016 to mitigate risks such as falls or structural failures.

Background on the Safety Standard for Portable Hook-On Chairs

Portable hook-on chairs are compact seating devices that clamp onto tabletops, allowing caregivers to position infants at adult height during meals or activities. The CPSC first established a mandatory safety standard for these products in 2016, incorporating by reference ASTM F1235-15. This action was required under section 104(b) of the CPSIA, which directs the Commission to issue safety standards for durable infant or toddler products. These standards must be substantially the same as applicable voluntary standards or more stringent if needed to reduce injury risks.

The initial standard included performance requirements, test methods, warning labels, and instructional guidelines to address hazards like instability, sharp edges, or inadequate restraints. In 2018, following notification from ASTM of a revision, the CPSC adopted ASTM F1235-18 as the new mandatory standard, effective after publication in the Federal Register (83 FR 48219, September 24, 2018). This version refined testing protocols and safety features based on incident data and engineering assessments.

ASTM International, a voluntary standards organization, develops these specifications through consensus among stakeholders, including manufacturers, consumer advocates, and regulators. The CPSC's involvement ensures alignment with federal safety goals, reflecting a collaborative approach to product regulation.

Details of the Proposed Revision: ASTM F1235-25

On January 20, 2026, ASTM notified the CPSC of its approval and publication of ASTM F1235-25, prompting the current notice. While the Federal Register entry does not detail specific changes, it references red-lined versions available on ASTM's website that highlight differences from the 2018 standard. Interested parties can access read-only copies of both versions online or purchase them from ASTM. The CPSC also offers inspection of copies at its Office of the Secretary in Bethesda, Maryland.

The notice emphasizes that the Commission is assessing whether the revision 'improves the safety' of portable hook-on chairs. Under CPSIA procedures, revisions to incorporated voluntary standards automatically become mandatory unless the CPSC rejects them within 90 days of notification, citing no safety improvement. If accepted, the new standard takes effect 180 days after notification, or later if specified.

Historical revisions, such as from 2015 to 2018, typically involved updates to address emerging hazards, like enhanced stability tests or clearer labeling to prevent misuse. For ASTM F1235-25, the CPSC invites comments specifically on its safety impact, drawing from incident reports, engineering analyses, and user experiences.

Legal and Procedural Framework Under the CPSIA

The process outlined in the notice follows section 104(b)(4)(B) of the CPSIA (15 U.S.C. 2056a(b)(4)(B)). This provision requires voluntary standards organizations to notify the CPSC of revisions. The Commission then has 90 days to reject the update by determining it does not enhance safety, thereby retaining the existing standard. Absent rejection, the revision becomes the mandatory consumer product safety standard under section 9 of the Consumer Product Safety Act (15 U.S.C. 2058).

This mechanism promotes timely updates while allowing public input. The notice specifies submission methods, including via regulations.gov (Docket No. CPSC-2015-0016), mail, or confidential channels for sensitive information. Comments must reference the docket number, and the CPSC may post them publicly without alteration.

Relevant precedents include prior CPSC adoptions of ASTM revisions for other infant products, such as bassinets or high chairs, where updates addressed specific injury patterns identified in the National Electronic Injury Surveillance System (NEISS) data. Stakeholders, including manufacturers and safety advocates, often provide perspectives on whether changes adequately mitigate risks without imposing undue burdens.

Key Players and Perspectives

The CPSC, an independent federal agency, leads this effort, with Lawrence Mella as the project manager in the Division of Mechanical and Combustion Engineering. ASTM International plays a central role as the standards developer. Other participants include manufacturers of portable hook-on chairs, who must comply with the eventual standard, and consumer groups focused on child safety.

Different viewpoints may emerge in comments. Industry representatives might argue that the revision streamlines compliance while maintaining safety, potentially reducing costs. Safety advocates could emphasize the need for robust testing to prevent incidents like chair detachment or pinching injuries, based on CPSC's incident data. Regulators balance these by prioritizing evidence-based improvements.

No specific legal challenges to prior hook-on chair standards are noted, but broader CPSIA implementations have faced scrutiny in cases like those involving phthalate bans or testing requirements, highlighting tensions between innovation and safety.

Implications and Potential Outcomes

Adopting ASTM F1235-25 could lead to short-term adjustments in manufacturing and testing, ensuring new products meet updated criteria. Long-term, it might reduce injury rates by addressing any gaps in the 2018 standard. If rejected, the current standard remains, potentially delaying safety enhancements.

The notice highlights the CPSIA's adaptive framework, allowing standards to evolve with technology and data. Ongoing debates center on the pace of revisions versus regulatory stability, and the role of public input in shaping federal rules.

In summary, this CPSC notice represents a critical step in maintaining safety for portable hook-on chairs. Potential next steps include reviewing comments by February 12, 2026, and deciding within 90 days of ASTM's notification whether to accept or reject the revision. Challenges may involve balancing diverse stakeholder input and ensuring accessibility of standards. Debates could focus on the adequacy of voluntary standards in preventing child injuries, informing future policy refinements.

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We are an education company, not a law firm. The information and content we provide is for general informational purposes only and does not constitute legal advice. We make no representations, warranties, or guarantees regarding the accuracy, completeness, or applicability of the content. It is important to always consult with a qualified attorney for specific legal counsel pertaining to your individual circumstances.

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